Case Digest (G.R. No. 45985)
Facts:
- Jose E. Pagsibigan, vice-president and general manager of Rentokil (Phils.) Inc., purchased a plane ticket for a Manila-Taipei-Hongkong-Manila flight on June 4, 1968.
- The ticket was issued by Philippine Air Lines (PAL) through Transaire Travel Agency, represented by Cecille Baron.
- CAL Ticket No. 017991 was issued on June 6, 1968, indicating a departure from Manila to Taipei on June 10, 1968, at 5:20 PM.
- Upon arrival at the airport on June 10, Pagsibigan learned that the flight had actually departed at 10:20 AM.
- PAL arranged for Pagsibigan to fly to Taipei the next day, June 11, 1968.
- Pagsibigan sought P125,000 in moral damages and P25,000 for attorney's fees, claiming embarrassment and mental anguish due to the error.
- The trial court found Espiritu solely responsible and awarded Pagsibigan P20,000 in exemplary damages, dismissing the case against CAL.
- Both PAL and Espiritu appealed, while CAL argued it should not be liable for PAL's actions.
- The Court of Appeals modified the ruling, awarding P20,000 as nominal damages and holding CAL jointly liable with PAL and Espiritu.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that China Air Lines, Ltd. is not liable for the negligence of Philippine Air Lines, Inc. and Roberto Espiritu.
- The damages awarded to Pagsibigan were modified to P10,000 as nominal damages, with PAL and Espiritu jointly and several...(Unlock)
Ratio:
- The decision was based on the principle of vicarious liability under Article 2180 of the Civil Code, which holds employers liable for their employees' negligent acts within the scope of their duties.
- The court determined that CAL did not have an employer-employee relationship with PAL or Espiritu, thus it could not be held ...continue reading
Case Digest (G.R. No. 45985)
Facts:
The case of China Air Lines, Ltd. v. Court of Appeals involves a legal dispute initiated by Jose E. Pagsibigan, who served as the vice-president and general manager of Rentokil (Phils.) Inc. On June 4, 1968, Pagsibigan purchased a plane ticket for a Manila-Taipei-Hongkong-Manila flight from Transaire Travel Agency. The travel agency, through its representative Cecille Baron, coordinated with Philippine Air Lines (PAL), which was acting as a sales and ticketing agent for China Air Lines (CAL). On June 6, 1968, PAL's ticketing clerk, Roberto Espiritu, issued CAL Ticket No. 017991, which indicated that Pagsibigan's flight was scheduled to depart from Manila to Taipei on June 10, 1968, at 5:20 PM. However, upon Pagsibigan's arrival at the airport on June 10, he was informed that the flight had actually departed at 10:20 AM that same day. PAL employees subsequently arranged for him to take a flight to Taipei the following day, June 11, 1968. Following this incident, Pagsibigan demanded moral damages from PAL, asserting that he experienced embarrassment and mental anguish due to the incorrect departure time on his ticket. He filed a complaint on September 22, 1969, seeking P125,000 in moral damages and P25,000 for attorney's fees, attributing the mistake to the negligence of Espiritu. The trial court found Espiritu solely responsible for the error and awarded Pagsibigan P20,000 in exemplary damages, dismissing the case against CAL. Bo...